Sub:- Complaint against Managing Director, Zenica Cars India Pvt. Ltd., Orchid Centre, Sector 53, DLF Golf Course Road, Gurgaon, Haryana – 122001 AND Managing Director, AUDI Approved Plus, C-1, Orient Bestech Tower, Sector 34, V.P.O. Khandsa, National Highway-8, Gurgaon, Haryana – 122004.
The undersigned is a Director (M.D.) of BRD Constructions Pvt. Ltd., having its registered office at 2 Sanjay Market, R Block, Greater Kailash, Part – 1, New Delhi – 110048.
That the undersigned on 01.06.2014 purchased a pre-owned AUDI A6 2.8 FSI Car from Zenica Cars India Pvt. Ltd., Orchid Centre, Sector 53, DLF Golf Course Road, Gurgaon, Haryana – 122001/a authorized dealer of pre-owned Cars of AUDI, bearing Registration No. HR 26 BS 1300 for the consideration of Rs. 31,50,000/- (Rupees Thirty One Lakh and Fifty Thousand Rupees).
That the undersigned at the first stage was hesitant to purchase the pre-owned car but on the assurance given by Zenica Cars India Pvt. Ltd., that the car is approved and certified by the AUDI Approved Plus and gone through various checks before being put again for sale, the undersigned agreed to purchase the car on the premise that at AUDI Approved Plus, the undersigned was assured of transparent and hassle free experience of purchasing a pre-owned vehicle/car, to create a culture of trust and confidence, so that a customer is not robbed of your peace of mind while engaging in the pre-owned car transaction.
That to the utter shock of the undersigned, the tall promises made Zenica Cars India Pvt. Ltd. and AUDI Approved Plus regarding the condition of the car and passing of the car through various checks before being put to sale again, fell flat as within 15 days of the purchase of the car and the undersigned started facing various problem with the car which has caused grievous mental agony and financial loss to the undersigned. The so called 55 Interior Check Points, 82 Exterior Check Points, 120 Engine Check Points, 22 Road Test Check Points and 30 Under Chasis Check Points alleged to have been conducted by the AUDI Approved Plus before selling the pre-owned car to the undersigned was nothing more than a deception and a honey trap to dupe the undersigned to part away with the hefty amount of Rs.31,50,000/-.
That the undersigned from the date of the purchase of the car and till date which is less than a year has made several complaints about the car one after the other and the nature of the complaints/faults in brief are mentioned as below:
(a) 17.06.2014 to 19.06.2014 (3 days): Vehicle/Car not starting.
(b) 07.07.2014 to 10.07.2014 (7 days): Under Body Shield Damaged.
(c) 16.08.2014 to 04.10.2014 (45 days): Car Engine Heating Up and Break Pads Worn Off.
(d) 29.10.2014 to 05.12.2014 (40 days): Coolant Leakage.
(e) 10.02.2015 to 01.03.2015 (20 days): Cam Shaft Censor Problem.
(f) 27.04.2015: Coolant Leakage – Still in the workshop for repairs.
(g) Tyres of car were old one and were defective made to wear and were got changed on two occasions.
That Zenica Cars India Pvt. Ltd. and AUDI Approved Plus deceived the undersigned and made him purchase a vehicle/car which is nothing more than a piece of scrap, by giving assurances about the condition of the vehicle/car.
That from the date of purchase of car i.e., 01.06.2014 till date, the vehicle/car has remained in the workshop for more than 115 days and even today it is in the workshop for the repairs.
That the undersigned has been cheated by Zenica Cars India Pvt. Ltd. and AUDI Approved Plus and has been deceived to part away with the huge amount of Rs.31,50,000/- (Rupees Thirty One Lakhs and Fifty Thousand Only) by deceiving me that the car being sold to him is technically sound and free from defects and has gone through various checks and is AUDI Approved Plus as mentioned above.
That the undersigned within few days of the purchase of the car started facing the problems with the car and through various e-mails on 07.07.2014, 19.08.2014, 23.09.2014, 03.11.2014 and 01.12.2014 has expressed his concern about the faults in the car and informed you accordingly. VIA emails dated 07.07.2014, 19.08.2014, 23.09.2014, 03.11.2014 and 01.12.2014
That it was shocking for the undersigned to know after seeing the service history of the car that the car has a long history of faults and repairs including accidental damages which were hidden from the undersigned by your company while selling this vehicle/car to the undersigned. Even the mileage meter of the car was tempered with by Zenica Cars India Pvt. Ltd. and AUDI Approved Plus to deceive the undersigned which is evident from the case history of the car itself. This conduct on part of Zenica Cars India Pvt. Ltd. and AUDI Approved Plus amounts to playing fraud with the undersigned and criminal breach of trust along with duping the undersigned by parting him of Rs. 31,50,000/- for a vehicle which was sold to me on the pretext of perfectly fit and sound in condition but, the same turns out to be a baggage of problems and nothing more than a scrap.
That the distorted facts were presented to the undersigned with regard to the condition of the car and I have been deceived to part away the amount of Rs.31,50,000/- by Zenica Cars India Pvt. Ltd. and AUDI Approved Plus by misrepresenting the facts with respect to the soundness and fitness of the car which is a criminal offence.
That the defective car fraudulently sold by Zenica Cars India Pvt. Ltd. and AUDI Approved Plus company has caused financial loss to the undersigned as he has purchased this car/vehicle on loan and is paying the regular monthly installments of Rs.79,715/- to the Bank.
That the fraud and misrepresentation played by Zenica Cars India Pvt. Ltd. and AUDI Approved Plus on the undersigned by selling a car with full of faults and problems, on the false assurances about the car being checked and approved by AUDI Approved Plus, has caused tremendous financial loss and mental harassment and the undersigned has been cheated and duped by them which amounts to criminal offence.
In view of the above facts and circumstances, you are requested to register the case against the Zenica Cars India Pvt. Ltd. and AUDI Approved Plus under relevant sections of the Indian Penal Code for cheating, duping, criminal breach of trust and misrepresentation of facts.